DATA PRIVACY STATEMENT

Schwan-STABILO Promotion Products

PREAMBLE

Schwan-STABILO Promotion Products GmbH & Co. KG welcomes you on its website and thanks you for your interest in our products. All personal data collected by Schwan-STABILO Promotion Products via this website will be used only for your individual support or in order to provide you with information regarding our products or services. Schwan-STABILO Promotion Products strictly adheres to the legal regulations concerning the protection of data privacy and will do everything possible to ensure the privacy of your data. All personal data will be therefore treated in accordance with this Data Privacy Statement.

1. RESPONSIBLE PERSON

The responsible person is: Schwan-STABILO Promotion Products GmbH & Co. KG, Schwanweg 1, 90562 Heroldsberg, Germany (hereinafter “Schwan-STABILO Promotion Products).

2. DATA PROTECTION OFFICER

Our Data Protection Officer is: Mr. Sebastian Meyer, Schwanweg 1 – 90562 Heroldsberg, Germany. Please refer to our Data Protection Officer if you have any questions regarding data protection issues at our company. You can reach him under the email-address: Datenschutz@schwan-stabilo.com.

3. GENERAL PRINCIPLES ON DATA PROCESSING

We collect and use personal data from our users basically only then, when this is necessary to provide a functional Website as well as to deliver our content and services.

3.1. Personal data
Personal data is all information relating to an identified or identifiable natural person. This includes, for example, information such as your name, email-address, address, date of birth or your phone number. Non-personal data is ex. data regarding the number of users at a website.

3.2. Processing of personal data
Processing of personal data is any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. We process personal data through our Website only if you provide us with this data, ex. when filling out our contact form or sending us an email. We process this data for the named purposes or for the purposes defined in your request. We do not disclose your personal data to third parties, unless otherwise provided by law or you have given us your consent thereto. Apart from that you may use the general information at https://www.stabilo-promotion.com without revealing your personal data. In particular we process your personal data as provided:

3.2.1. Newsletter
In order to subscribe to our e-mail newsletter, apart from your consent, we will need your e-mail address, to which we will send the newsletter, as well as your language, country and category of company. You may further on decide to provide us on a voluntary basis with the name of your company, your title, as well as your first and last name. You may freely decide, whether you want to provide this information to us. Without this information we will however not be able to send you a personalized newsletter. In certain cases, without providing certain information it may also not be possible to send you a newsletter at all. The following table gives you detailed information, what type of personal data will be processed by us:
- Company (voluntary)
- Title (voluntary)
- First and last name (voluntary)
- Language
- industry
- Country
- E-mail-address
When subscribing to our newsletter we use your e-mail address for our own advertising purposes until you have unsubscribed. For unsubscribing you may send us an e-mail to: service@stabilo-promotion.com or you can follow the link in each newsletter.

Your personal data will be stored for the time you have subscribed to the newsletter. Upon unsubscribing your personal data will be deleted. You can unsubscribe at any time and for any reasons. Any further storage of your data may however take place, if storage is required by law. The data processing described above is carried out in accordance with article 6 (1) lit. a GDPR (your consent).

3.2.2. Registration (Account)
At our website we offer you the possibility to register using your personal data and to have a personalized customer account. This customer account allows you to use certain services and content, for example you may order products comfortably from the customer account and using a chosen login and password.

In this context your e-mail-address will be used for the purposes of sending you new login data, should you lose or forget them.

The following table gives you detailed information, what type of personal data will be processed by us, if you have a customer account:
- Company
- Title
- First and last name
- E-mail-address
- Address
- Telephone number (voluntary)
- Fax number (voluntary)
- Department (voluntary)
- Industry (voluntary)
- Position (voluntary)
- Category (voluntary).
The data processing described above is carried out in accordance with article 6 (1) lit. b GDPR.

As soon as you deregister or change your registration, your data will be deleted or altered. Any further storage of your data may however take place, if storage is required by law.

3.2.3. Inquiry form
At our website we offer you the possibility to send inquiries regarding our products with registering.

The following table gives you detailed information, what type of personal data will be processed by us if you send us an inquiry using the inquiry form:
- Title
- Company
- First and last name
- E-mail-address
- Address (voluntary)
- Telephone number (voluntary)
The data processing described above is carried out in accordance with article 6 (1) lit. b GDPR.

3.2.4. Form for samples
Through our newsletter you can reach form for samples. Via this form you may order a sample of a product which was presented in our newsletter. This is however only possible, if you provide us with at least your company name, your first- and last name, as well as your address and e-mail-address. For any questions you may provide us voluntary with your telephone number.

The following table gives you detailed information, what type of personal data will be processed by us if you send us an inquiry using the inquiry form:
- Company
- First and last name
- E-mail-address
- Address
- Telephone number (voluntary)
The data processing described above is carried out in accordance with article 6 (1) lit. b GDPR.

3.2.5. Contact
You can contact us by sending us an e-mail to: service@stabilo-promotion.com. Basically, to answer your question or request, we will need your email-address, which will be used to answer your question or reply to your request. The data processing described above is carried out in accordance with article 6 (1) lit. b and article 6 (1) lit. f GDPR. As soon as your question or request has been answered or completed, your personal data will be deleted. Any further storage may however take place, if storage is required by law.

3.2.6. Job applications
If you are interested in our job offer, you can send us an application per email using the following email address: job@schwan-stabilo.com or per mail.
We assure you, that we will process your personal data only for the purposes of carrying out the job application process. Your personal data will be stored for 6 months after concluding the job application process.
The data processing described above is carried out in accordance with article 6 (1) lit. b GDPR.

3.3. Legal basis
Collecting and processing your personal data takes generally place upon your consent. Should the data processing be based on your consent, the legal basis for this data processing is Article 6 (1) lit. a GDPR. An exception may occur when obtaining a consent is not possible and/or this is permitted by law. If processing your data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, the legal basis for this data processing is Article 6 (1) lit. b GDPR. If processing your personal data is necessary for compliance with a legal obligation to which we as the controller are subject, the legal basis for this data processing is Article 6 (1) lit. c GDPR. If processing your personal data is necessary for the purposes of legitimate interests pursued by us, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, the legal basis for this data processing is Article 6 (1) lit. f GDPR.

4. COOKIES

Below we describe the processing operations connected with usage of cookies, sessions and logfiles.

4.1. Usage of cookies, sessions and logfiles
A cookie is a small text file stored in your browser cache and enables an analysis of your use of our Website and/or ensures the functionality of the Website. Further our partners use cookies in order to evaluate the user behaviour for advertising purposes (social targeting). A session is a single session which will be saved on our server for a short period of time. Logfiles are created by the server and stored by us. They contain automatically generated logs of all or specific activities of processes on a computer system.

4.2. Data collected by cookies
Except for the IP address, no personal data will be stored in the cookies, sessions and logfiles. Furthermore, these files cannot transfer viruses, spy on your computer, or send emails undetected. In addition, each webserver can only read out those cookies it placed itself.

The following data is automatically collected via cookies, sessions and logfiles when you call up our Website:
- Your internet address (IP address) / host name
- Agent/browser type and version
- Website you were referred from (referrer URL)
- Operating system used
- Pages viewed on our Website
- Date and time of access
- Session ID (for registered users)
This data is stored separately from the data you provided to us and is not linked with other personal data. The data processed according to 4.2. is processed for statistical purposes, in order to optimize our Website and our offer.

4.3. Google Analytics
This Website uses Google Analytics, a web analysis service from Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Irland ("Google"). Google Analytics uses Cookies to make it possible to analyze your use of our Website.

Information about your use of our Website generated by cookies, ex. Time, place and frequency of use of the Website, is usually transferred to a Google server in the USA and saved there. When using Google Analytics, it may not be excluded, that apart from the IP address Google processes further personal data. Please be informed that such information may be transferred by Google to third parties, if this is required by law or if Google contracts third parties to process such data.

Google will use the information gathered by the cookies to evaluate your use of the Website in order to compile reports about Website activities for us and provide additional services associated with the Website and Internet usage. According to Google, Google will not associate your IP address with other personal data collected by Google.

You have the option to prevent Google from acquiring and processing data generated by cookies and data related to your use of our Website (including your IP address) by downloading and installing a Google-provided browser plugin. More information about Google Analytics Opt-out function can be found at: https://tools.google.com/dlpage/gaoptout?hl=en . Please be informed, that in such an event, not all functions of this Website may be available to you. This plug-in prevents Google Analytics from giving you information about your visit to the site. This plug-in does not prevent any other analysis.

Please note that you cannot use the browser plug-in described above when visiting our website via the browser of a mobile device (smartphone or tablet). When using a mobile device, you can prevent Google Analytics from capturing your usage data by clicking on the following link: Google Analytics deaktivieren. By clicking on this link a so-called opt-out cookie is placed in your browser. This will prevent Google Analytics from giving you information about your visit to the site. Please note that the opt-out cookie is only valid for this browser, and only for this domain. If you delete the cookies in this browser, the opt-out cookie will also be deleted. To continue to prevent Google Analytics from capturing, you must click the link again. The use of the opt-out cookie is also possible as an alternative to the above plug-in when using the browser on your computer.

In order to ensure the best possible protection of your personal data, Google Analytics has been extended by the code “anonymizeip” on this website. This code causes the last 8 bits of the IP addresses to be deleted and their IP address is thus collected anonymously (so-called IP-masking). Your IP address will be shortened by Google in principle, even before the transfer within Member States of the European Union or in other contracting States of the Agreement on the European Economic Area and thereby anonymized. Only in exceptional cases will the full IP address be transferred to a Google server in the United States and shortened there.

4.4. Prevention of cookies
If you object to the use of cookies, sessions and logfiles, you can block or restrict their usage in your browser. However, it cannot be ruled out that in this case you might not be able to use individual functions on our webpages.

Upon closing your browser, the session-cookies are deleted, other cookies after one year. Cookies from our Partners, ex. Google (4.4) are deleted maximally after 24 months. You can deactivate the usage of cookies by Google by means of visiting the deactivating site of Google. Alternatively, you may deactivate the usage of third party cookies by means of visiting the deactivating site of the network initiative.

4.5. Legal basis

In case of Cookies, technically needed for a functioning website, the legal basis for this data processing is Article 6 (1) lit. f GDPR (a company´s legitimate interest).
In case of marketing, tracking and analyzing Cookies the legal basis for the data processing is Art. 6 (1) lit. a GDPR (consent).

5. DATA SECURITY AND PRECAUTIONARY MEASURES

We are committed to protecting your privacy and treating your personal data confidential. In order to avoid any manipulation, loss or misuse of your data stored by us, we take extensive technical and organizational security measures that are regularly reviewed and adapted to technological progress. Intensive training of our employees and their obligation to data security ensure that your personal data is treated confidential.

5.1. Responsibility of the User
We urge you to also take all possible measures to protect your data while working on the internet. Due to the structure of the internet, it is not possible for us to ensure that third parties, which are not within the scope of our responsibility, adapt identical privacy and security measures. Possibly if personal data is not encrypted or is sent per email it may be seen or read by third parties. Hereto we have no impact. It is the responsibility of the User, to secure his/her data via encryption or by other means.

5.2. Encryption
We use the SSL (Secure Sockets Layer) to encrypt your data on all Websites which require providing personal data. SSL encryption masks your data before transmitting it to our server, in such a manner that it cannot be reconstructed by third parties. This safeguards the privacy of your personal data.

6. SERVICE PROVIDERS FOR PROCESSING PERSONAL DATA

We employ service providers, who process personal data on our behalf and only on our instruction. The service providers are required to comply with all data protection regulations and to process data in accordance with our instructions. Our service providers have been carefully selected and receive access to your personal data only to the extent and for the time necessary to carry out their services.

Service providers in third countries such as the USA and countries outside the European Economic Area are subject to data protection regulations, which do not protect personal data to same extent as in the European Union. Should we process your personal data in countries, which do not provide such a high level of data privacy as in the European Union, then we will ensure by means of contractual regulations and other instruments that your that your personal data is safe and adequately protected.

7. STORAGE PERIOD

Your data will be stored only for the period of time required by law. Your data will be erased, when you have withdrawn your consent for processing your data or the purposes of processing your data have been obtained or when the processing is no longer legitimate for any legal reasons. Any retention periods required by law shall remain unaffected. During the statutory retention periods your data will not be processed for other purposes.

8. RIGHTS CONCERNED

From the GDPR, the following rights arise for you as an affected person for the processing of your personal data:

8.1. Right of access
According to art. 15 GDPR, you can request information about your personal data processed by us. In particular, you may request information on the source of the data, the recipients of this data or categories of recipients, as well as the processing purposes.

8.2. Right of objection
If the processing of personal data is based on your consent, you may object to this processing for the future, at any time and without any reason. To do so please send an email to: service@stabilo-promotion.com or a letter to: Schwan-STABILO Promotion Products GmbH & Co. KG, Schwanweg 1, 90562 Heroldsberg, Germany.

8.3. Right to rectification
In accordance with art. 16 GDPR, you can immediately request the rectification of incorrect or the completion of your personal data stored by us.

8.4. Right to erasure or restriction
In accordance with art. 17 GDPR, you may request the deletion of your personal data stored by us. The personal data will be deleted within 7 working days from your request. Any retention periods required by law shall remain unaffected. If your data may not be deleted due to retention periods, only a restriction of processing may be applied. Upon deleting your data, no access right may be granted.

8.5. Right to data portability
According to art. 20 GDPR, you may request to receive your personal data that you have provided to us in a structured, common, and machine-read format, or you may request the transfer to another responsible person, insofar this is possible to due technical means.

8.6. Right of revocation
In accordance with art. 7 (3) GDPR, you can revoke your once given consent to us at any time. As a result, we are not allowed to continue the data processing based on this consent for the future. In such an event you may not access our company sight.

8.7. Exercising the rights concerned
To exercise the aforementioned rights, please contact us at: service@stabilo-promotion.com or per mail to: Schwan-STABILO Promotion Products GmbH & Co. KG, Schwanweg 1, 90562 Heroldsberg, Germany. Your personal data (possibly your email, name and telephone number) will be processed in order to answer your questions or respond to your concern. This data will be deleted if no longer necessary; in the event of statutory retention periods – the processing may only be limited.

9. COMPLAINT TO A SUPERVISORY AUTHORITY

According to art. 77 GDPR, you have the right to complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of stay, your workplace or our company headquarters.